How do I demonstrate the share of recycled aluminium?

What you must concretely do

What is expected of you

Disclose the share of recycled material if it is a required data field

Article 10 of the ESPR (Regulation (EU) 2024/1781) mentions the share of recycled material as an example of information that may be included in a product passport. Whether this will actually become a mandatory field for aluminium semi-finished products, and with what precision, will only be determined once the delegated act for aluminium is published. For a company with 10 to 100 employees, this means above all: now examine whether the company's own production records can substantiate a share of recycled material, so that no backlog arises when the act is published. Which data are exactly required is described on the page on which data will be included in the aluminium product passport.

Substantiate the share with a measurement or calculation method

Article 39 of the ESPR (Regulation (EU) 2024/1781) provides that test, measurement and calculation methods are to be established to make reported values comparable and verifiable. For the share of recycled aluminium, this means that a percentage alone is not sufficient: there must be a method behind it with which that percentage has been calculated. For one company this is a mass balance over the melt charge, for another a bookkeeping allocation over a longer period. Which method will apply for aluminium has not yet been published; the general system is explained on the page on the method by which the values for the passport are measured. From a practical standpoint, this means that for a production company the origin of scrap and the manner of recording it can now already become part of the internal quality administration, even without the final calculation rule being established yet.

Distinguish between pre-consumer and post-consumer scrap

In the aluminium sector, a distinction is generally made between scrap from the company's own production process (pre-consumer) and scrap from discarded products (post-consumer). The ESPR itself does not mandate this distinction for Article 10 or 39, but the delegated act may require this distinction because the share of post-consumer scrap is generally considered more relevant to the environmental performance of a product. A foundry that returns both its own production residue and external scrap to the melt is well-advised to record these streams separately now, so that a later requirement to subdivide does not have to be reconstructed retroactively in the records.

Keep the share current per batch or delivery

A percentage of recycled material is not a fixed property of an alloy, but an outcome of the production charge. This means that the share can differ per batch, coil or delivery, and that the passport is therefore not filled in once and forgotten. How often a value in the passport must be updated if the underlying production changes is explained on the page on how current the data in the product passport must be. For a medium-sized company, this means that the link between ERP system or production records and the passport is ideally not manual entry per shipment, but a permanent export from existing data.

Where things go wrong in practice

A profile manufacturer provides an average annual percentage for all deliveries, while the actual composition per coil differs — in a later inspection at batch level, the stated percentage does not match the specific delivery.

A foundry counts its own production residue (which would return to the recycling loop anyway) as part of the recycled share, without distinguishing it from scrap of external origin, so that the reported percentage is higher than the sector would consider comparable.

An importer of aluminium semi-finished products adopts the percentage from the foreign supplier without explanation in the passport, without knowing which calculation method underlies it — if asked to substantiate, there is then nothing to fall back on.

A company internally records the share of recycled material for its own environmental reporting, but in a different unit and at a different aggregation level than the product passport will later require, which means the existing data cannot simply be reused.

A packaging producer confuses the share of recycled material with the CO2 emissions of the product — both are related, but they are two different data fields with possibly different calculation rules; anyone wanting to know more about this can visit the page on demonstrating CO2 emissions per tonne of aluminium .

What you can document now

• The origin of scrap streams per supplier or internal source, with date and quantity, so that a percentage of recycled material can be traced back afterwards.
• A fixed calculation model (mass balance or accounting allocation) with which the share per batch or period is determined, including the assumptions made in the process.
• Substantiation from suppliers when a percentage of recycled material is adopted from a supplied certificate or supplier declaration.
• A link between production recording and the data that goes into the product passport, so that a change in the melting charge automatically carries through to the reported value.
• An internal agreement on the distinction between pre-consumer and post-consumer scrap, even if the delegated act does not yet mandate this distinction.
• An overview of which fields in the product passport are linked to other mandatory data, such as the alloy designation; how that recording looks is shown on the page on recording the alloy and the EN-AW designation.

Once the delegated act for aluminium has been published, this section of the knowledge base will be supplemented with the exact calculation rule and the required level of detail.